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Zipcar (UK) Ltd. ("Zipcar") and its subsidiaries and affiliates (also referred to as "we," "us," "our" or "Zipcar group") respects your privacy. This privacy notice describes the personal information we collect from you and how we use that information. It also sets out choices that you have in respect of our use of your personal information.

This privacy notice covers both our collection and use of information when you use zipcar.co.uk and our European Union websites located at avancar.es, zipcar.fr and zipcar.be and their related mobile sites and applications (collectively, our "Sites"), as well as the kinds of information we collect and use when you join Zipcar and use our services. A full list of the European Union Zipcar group companies and contact details are included below, which also details the primary data controller when you use our Sites. This privacy notice does not apply to Zipcar group sites in the US and Canada (please refer to zipcar.com and zipcar.ca, respectively). This privacy notice does not apply to other third party Internet or mobile sites or applications even if accessed via our Sites (please refer to the privacy notice for those specific third party sites). Please take the time to read this privacy notice as it is important for you to know how we collect and use your personal information. By submitting your personal information to us, you acknowledge and accept that Zipcar will use and disclose your personal information as set forth in this privacy notice. Where any use or disclosure requires specific consent, Zipcar will only use and disclose the personal information in line with the consents you have given to Zipcar. If you do not agree with the terms of this privacy notice, please do not submit any personal information to Zipcar.

This privacy notice is incorporated into, and forms part of, the Zipcar Membership Contract and the Terms of Use, which governs the use of zipcar.co.uk and the other Sites.

We may change portions of this privacy notice from time to time, so be sure to check it on a regular basis. If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how we use your personal information, we will notify you by way of a prominent posting on our websites, e-mail and/or postal mail prior to the change becoming effective.

If you have any questions or concerns regarding our privacy notice, please contact us at dpo@zipcar.com or in one of the ways provided in the Contact Information section at the end of this privacy notice.

what is personal information?

In this privacy notice "personal information" means information that identifies you as an individual, or that we can combine with readily available information to identify you as an individual.

what personal information we collect and how we use it

The principal purposes for which we collect and store your personal information are to process your application, allow you to reserve and use our vehicles, authorise payment, bill you, respond to your enquiries, improve our products and services and maintain your account with us. We will use your personal information including where:

this is necessary to enter into or perform our contract with you – for example, using your contact details and payment details to supply products and services you want to purchase.

this is necessary to comply with legal or regulatory requirements – for example, disclosure of information to law enforcement if you are involved in an accident during your reservation, or suffer any loss, damage or theft of the vehicle, or if you incur any speeding, parking, toll or other traffic-related fines or commit any traffic offences during your reservation.

this is necessary in the public interest – for example, undertaking measures for anti-fraud screening and verifying our member's identities.

we have collected your consent – for example, in order to send you direct marketing messages. You can opt-out at any time by using the opt-out in a marketing message or withdraw your consent at any time (in your account preferences or settings) or by contacting us as set out at the end of this privacy notice.

this is necessary for the purposes of our legitimate business interests (provided that we have balanced these against your rights and interests).

Our legitimate interests include: (a) to ensure effective administration and management of your relationship with us, including any reservations with us; (b) to understand how our members use our services and to manage our vehicle fleet; (c) to carry out research and analysis on what services or products our members want or how they would like us to improve our services and products; (d) to understand how our members use our Sites and identify any issues in how the Sites are used and how we can improve the members’ usage experience; (e) to tell our members about the various products and services we can offer; (f) understand and respond to member feedback; (g) to better tailor and personalise the promotions and benefits that we offer to our members; (h) to prevent, detect, or investigate unauthorised use of our vehicles and systems and ensure we comply with law and our policies; and (i) manage any disputes and accidents and take legal or other professional advice.

We have set out below further details on the information we collect, store and why we use it.

When you use our Sites, our servers automatically log certain information about your use of our Sites, such as your IP address, your browser type, operating system, browser language and service provider. We also collect information about your activities on our Sites, such as the pages you visit or the ads or links you click on. We use this for a number of purposes, where we have a legitimate interest to do so, such as: improving our services, developing new services based on what we learn from your activity; identifying products and marketing that may be of interest to you; personalising our service to you; and carrying out statistical analysis and research with the purpose of allowing us to better understand our members and the products / services they want. We also use this information to provide and adapt our services to take account of the technical capabilities of our users as well as identify issues with the website and user's experience of it.

IP Addresses and other information collected automatically: We may collect your IP address when you visit our websites to help us diagnose problems with our systems, for system administration, to report aggregated information to our business partners, and to audit the use of our website. In select circumstances, we may use IP addresses to help us identify you to protect our service, site, users or others. We also collect your browser type, Internet Service Provider (ISP), referring/exit pages, the pages viewed on our site, operating system, date/time stamp, and/ or clickstream data to analyse trends in the aggregate and administer the site.

Session Replay: When you visit our website, we may also record information about your browsing session on the site, including which pages you visited and any forms on the website that you filled in. We review this information to identify any technical issues in the operation of our sites and to improve the user interface on our sites. If we use a third party to help us with this service, this information will be passed to that third party for this purpose.

Mobile Analytics: When you download and use our apps, we may use mobile analytics software to help us better understand the functionality of our app on your mobile device. Our analytics may record how often you use the app, how you use the app, aggregated usage, performance data and where you downloaded the app from.

Mobile GPS and Push Notifications: If you allow us, when you use our apps we may collect location markers using the GPS in your device. Knowing approximately where you are would help the app provide you better service, such as finding the nearest Zipcar location near you. This would also help us send you push notifications or other communications based on your location (for example, nearby special offers) and for providing certain services such as return notifications, providing information about vehicle location, etc. We will only share this information with third party providers for the purpose of providing you these services. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information. If you change your mind about sharing your location or receiving push notifications from the app, adjust the settings of your mobile device to turn off transmission of geolocation data or to stop transmission of push notifications at any time.

Zipcar collects information that you voluntarily submit to us, which could include your name, email address, postal address, telephone number, or a picture of you or identifying documents. This also includes information in your profile or information you provide to us via an email, or similar message, telephone call, or by other means. Your telephone calls and other correspondence with us may be recorded or monitored for quality control, training and similar purposes. We use this information in connection with providing you with our services and managing your account as outlined elsewhere in this privacy notice.

If you apply to join Zipcar, join Zipcar and use our services, we collect personal information as you proceed through the stages of our application process, membership agreement and reservation process.

When you become a Zipcar member or make a reservation, we collect information to provide you with our services, (for example, fulfilling a vehicle reservation, providing any requested optional extras, taking payment, pre-authorisations and/or security deposits and providing discounts and offers or other benefits) and for our legitimate business interests (for example research and development of new products and services and enforcing our legal rights). The information we collect may include:

other information that may be required to provide you a vehicle and/or provide you with services.

As part of your application or membership, we may also collect information such as your driving record from regulatory bodies or from third parties.

Where you inform us that you require an adapted vehicle or other driver aid we will use that information in order to provide you with the service you requested where you have given your explicit consent to us using that information or: (1) the use is necessary to protect your vital interests in an emergency or those of another person; (2) the relevant information has been made public by you; (3) the use is necessary or in connection with legal claims or court proceedings; or (4) the use is necessary for reasons of substantial public interest – for example, driving safety.

In connection with your membership, we will collect where and when you searched for, reserved or picked up a vehicle, where and when you returned a vehicle, waiver or insurance preferences, fuel consumption, mileage, accident history and other information related to a Zipcar vehicle and your use of it. This information is required in order to provide you with the services you requested under the member contract or for our legitimate business interests (for example to monitor the usage of our vehicle fleet).

Sometimes, we will combine the personal information we receive from you with other information we received from other sources so we can provide you a more customised experience. This information may include your name, contact information, reservation details and other information that is relevant to your reservation. These third parties include:

Universities if you are using an affiliated account;

Your employer or association if you are using a corporate / association account;

Our licensees and our affiliates, in order to create a Zipcar membership account or if you are making a reservation in one location served by our affiliates or licensees for reservations in another location served by us;
and

Police and other law enforcement agencies if you are involved in an accident during your reservation, or suffer any loss, damage or theft of the vehicle, or if you incur any speeding, parking, toll or other traffic-related fines or commit any traffic offences during your reservation.

If you have an accident, or suffer any loss, theft or damage to the vehicle during your reservation or suffer any mechanical failure, we will collect information regarding such incident including your report of the incident and any police or other third party report including details of those involved, together with the nature of any personal injuries and/or damage to the vehicle and optional extras. We will use this information to provide services to you (for example, under the member contract and/or the terms of any optional extra like the damage fee waiver); for our legitimate business interests (for example, in recovering the costs of any loss or damage caused to the vehicle); for complying with any legal obligation on us (for example, making any required notification of the incident to appropriate authorities); and establishing, exercising or defending legal claims arising as a result of such incident.

We will also collect information about any speeding, parking, toll or other traffic-related fines that you incur or any traffic offences that you commit during your reservation where these are provided to us by any law enforcement agency. We will use this information to deal with such fine or offence in accordance with the terms of your member contract with us.

When you call or text us (from any phone), or e-mail us, we may record or monitor the communication for quality control, training or similar purposes.

In addition to the purposes listed above, we use this information to better understand our members and may provide you with relevant offers.

Please be aware that, in certain circumstances, where you do not provide personal information which is required by us, we will not be able to provide the products and services under our contract with you or may not be able to comply with a legal obligation on us. For example, when reserving a vehicle with us we will require information such as your name, address, payment information and driver's license. If you fail to provide this information to us we will be unable to provide a vehicle to you. You will be made aware if this situation arises and what the consequences of not providing the personal information will be.

Automated Decisions may be made by us regarding you in respect of validation of driver licence details or other identify checks. If you disagree with the decision you are entitled to contest this by contacting us by using the details at the end of this privacy notice.

Where permitted by local law, Zipcar may use Global Positioning System (GPS), telematics data tracking technology and anti-theft technology that uses GPS. GPS is a network of satellites that would allow us to determine the location (latitude and longitude) of Zipcars during your reservation. Additionally, Zipcars may also have an on-board device that may monitor the state of the vehicle from moment to moment, including its location during your reservation. This information would be transmitted to Zipcar and stored. Where applicable, Zipcar uses this information for a variety of legitimate interests and also in connection with the performance of our contract with you. For example, we may monitor or store vehicle or GPS data to help you find a car you have reserved, to assist with roadside assistance and to locate lost or stolen Zipcars.

If used, telematics data tracking technology allows us to monitor driver behaviour of members to aid in reducing fraud or in an accident situation. In addition, at an anonymous and aggregated level, insight can be obtained about Zipcar usage. We have a legitimate interest in using the information in this way as well as there being a public interest in the responsible use of vehicles.

Zipcar may have access to video surveillance systems as well as cameras, where indicated by signage at the relevant Zipcar group location, that record activity at our Zipcar pods.

children's privacy

We do not knowingly solicit or collect individually identifying information from children under the age of 16. If you are under 16 years old, you may not submit any personal information to us or subscribe for services. If you believe we might have any personal information from or about a person under the age of 16, please contact us.

where we hold personal information

Reservations

As we offer the ability to reserve vehicles and benefit from our services in various locations globally, we may transfer your personal information to our affiliates and independent licensees in these locations for the purposes of fulfilling your reservation and/or entering into a member agreement. The exact location of where your personal data will be transferred depends on the location of your reservation.

These transfers are made either as they are necessary for the performance of a contract to which you will be a party, or for pre-contractual measures. Alternatively, adequacy of data protection is ensured by standard data protection clauses that we have in place with the relevant recipient. A copy of these standard data protection clauses may be requested via our Data Protection Officer at the address set out in the Contact Information section.

Business operations

In addition, the information we collect from you may be transferred to, and stored by, IT vendors who operate on our behalf. We also transfer information to a number of providers of business applications. These providers are primarily located in the United States.

The United States does not benefit from a decision issued by the EU Commission regarding protection afforded to personal information. Adequacy of data protection is instead ensured by standard data protection clauses we have in place with that third party. A copy may be requested via our Data Protection Officer at the address set out in the Contact Information section.

Given the global nature of our business, we also transfer information within the Zipcar group companies as for certain activities the group uses shared IT functions. Transfers from within the European Union for these purposes are primarily made to the United States, although transfers may be made to other countries as well. The United States and many of the other countries located outside the European Union do not benefit from an adequacy decision issued by the EU Commission regarding protection afforded to personal information in that country. Adequacy of data protection is instead ensured by standard data protection clauses we have in place with the recipient. A copy may be requested via our Data Protection Officer at the address set out in the Contact Information section.

how long do we keep your information

We will keep your information for as long as it is reasonably necessary. It will depend on factors such as whether you've any reservations upcoming or in the past or an account with us or have interacted with recent offers. We will also retain your information as necessary to comply with legal, accounting or reporting requirements.

The criteria we may use to determine the retention period for certain categories of data is as follows:

the length of time that you are a member of Zipcar;

how frequently you reserve with us or when your most recent reservation occurred;

whether there are contractual or legal obligations that exist that require us to retain the data for a certain period of time;

whether there is any ongoing legal or financial claim that relates to any reservation you have made with us, or that is otherwise related to your relationship with us;

whether any applicable law, statute, or regulation allows for a specific retention period;

whether the personal information is considered to be a special category of personal information, in which case a shorter retention period generally would be applied; and

what the expectation for retention was at the time the data was provided to us.

to what third parties might we transfer personal information?

Except as described in this privacy notice, Zipcar will not share your personal information with third parties outside the Zipcar group unless it is necessary to provide the Zipcar service, fulfil a transaction you have requested, or in other circumstances with your consent.
We do disclose your personal information within the Zipcar group so we can provide the best service across our group. They are bound to keep and use your information in accordance with this privacy notice.

Zipcar may use and share your personal information and vehicle data to affiliated and non-affiliated organisations as follows:

Third party recipient

Purpose of disclosure

Legal Basis for Processing

Credit card issuers in order to obtain payment from you

Process payments and refunds;

Fraud check;

Handle debt collection.

Performance of Contract.

Legitimate Interests

IT service providers including IT platform providers and website analytics service providers in order to perform our contract with you and to understand how you use our services and to improve our business

Support our IT systems and infrastructure;

Provide maintenance services for our IT systems and infrastructure;

Provision of data hosting and other data processing services;

Provide analytics services relating to your use of our website to identify any technical or user interface issues and/or improvements in connection with the website

Legitimate interests

Corporate or university account manager in order to provide you with benefits of a corporate or university program and to understand how you use our services and to improve our business

If you are reserving with a corporate membership or other similar commercial entity account, we may share personal information with the organisation that manages the account for their own purposes. We recommend you review their privacy policy or other disclosures to you to learn more about their privacy practices.

Performance of Contract

Legitimate interests

Your employer or organisation in order to provide you with benefits of a corporate or association program and to understand how you use our services and to improve our business

Verify drivers licenses or other government identification.

Verify eligibility to use designated account and discount codes;

Connect with your corporate and commercial accounts.

Performance of Contract

Legitimate interests

Independent licensees / franchisees and network providers in order to perform our contract with you and to understand how you use our services and to improve our business

Make and confirm your reservation;

Connect with your corporate and commercial accounts;

Assist with navigation assistance or itinerary planning;

Provide member assistance;

Resolve toll, traffic or parking violations;

Processing any claims relating to accidents and/or injuries;

Providing roadside assistance services;

To protect or defend the rights or well-being of us, our employees, members or others;

Verify driver criteria for qualified drivers.

Performance of Contract

Legitimate Interests

Legal obligation

Consent

Government, regulatory and law enforcement agencies in order to meet our legal obligations

As requested by these agencies if the disclosure is required or permitted by law;

To take action regarding illegal activities, traffic offences or violations of terms of service;

If we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person; and

As otherwise required or permitted by law.

Legal Requirement

Legitimate Interests

Insurance companies and claims handlers in respect of any insurance product you purchase in connection with your reservation

Provide and service the insurance product you have requested;

Manage any claims that may be made under the relevant insurance policy.

Performance of contract

Legitimate interests

We may also transfer or assign your personal information to third parties as a result of, or in connection with a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganisation, or liquidation. Or if we are involved in defending a legal claim, information about you that is relevant to such claim may be disclosed to third parties as a result of, or in connection with, associated legal proceedings.

We may, in accordance with the Direct Marketing section, share your information with business and promotional partners (where you have provided your consent to such information sharing) in order to send you information about products and services you may like. If you decide you no longer want to receive such promotional and marketing messages, please see the Direct Marketing section to find out how you can opt-out.

Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

independent licensees

Reservations of certain Zipcar vehicles may be operated by an independent third party licensee not owned or controlled by Zipcar, and in those instances this privacy notice does not apply. Each independent licensee may collect personal information and use the personal information for its own purposes. Zipcar does not control the independent licensee's use of personal information. For credit card transactions, the independent licensee, not Zipcar, may collect and process credit card information and receive payment for the Zipcar services. In this case, the independent licensee is subject to the merchant rules of the credit card processors it selects. This privacy notice also does not apply to any independent licensee's website. These licensees may also use email campaigns and other methods of telephone, electronic and direct mail solicitation without our consent or knowledge and are solely responsible for their content and methods of identifying and contacting addressees.

direct marketing

Zipcar may use personal information you give us for direct marketing purposes to provide updates; newsletters; events; offers or other communications that we think may interest you. We will only do this with your consent or where we otherwise have a legitimate interest to do so and are permitted to by applicable law.

We may share personal information with third parties to help us with our marketing and promotional projects, or sending marketing communications.

If you want to opt out of receiving promotional and marketing emails, text messages, post and other forms of communications from Zipcar or our promotional partners in relation to which you might receive in accordance with this section, you can best opt out by using one of the following ways:

Log into your account and update your profile.

Click "unsubscribe" at the bottom of an email we sent you.

Go to our Contact Information section to email the representative suited for you.

If you do opt out of receiving promotional and marketing messages, we can still contact you regarding our business relationship with you, such as account status and activity updates, survey requests in respect of products and services we have provided to you after you reserve from us, reservation confirmations or respond to your inquiries or complaints, and similar communications.

If you want to close your account, stop doing business with Zipcar, or otherwise opt out of Zipcar collecting, using or disclosing your personal information, please contact member services in accordance with the Contact Information section.

Please also see your rights set out in Understanding Your Rights section.

cookies, advertising and personalised content

We use third party tools to make the advertising we show you on our Site more relevant and interesting to you. For this purpose, we use cookies, web beacons or similar technologies to collect information about your browsing behaviour (see our Cookies Notice at the end of this privacy notice for more detailed information) and deliver interest-based ads to you.

We use cookies that identify your browser or device. They collect and store information when you visit our Site about how you use it. For more information about cookies, the types of cookies we use and how we use them please see our Cookies Notice.

Zipcar may also use third party ad network providers and other service providers to help present customised content and offers across various platforms, including the Internet or our Sites. These providers use cookies, web beacons, or similar technologies on your computer to help present, better target, and measure the effectiveness of their content and advertisements, using data gathered over time and across their networks of web pages to determine or predict the characteristics and preferences of their audience. We may share certain non-personal information about you (such as age and post code) with certain ad network and service providers to help them deliver more relevant content and advertisements through their networks. The use of cookies, web beacons, or similar technologies by content and ad network providers is subject to their own privacy policies, not ours.

We may use analytic software, such as Adobe Analytics, Google Analytics and others, to help us to better understand the functionality of our software on our websites and apps on your device. These software tools record technical information including about your device together with usage information such as how often you use our website or app, which features you use or don't use in the website, app or which pages you visit on the website, aggregated usage, performance data, where the app was downloaded from and information about your visit to the site, including details of some of the URL clickstream to, through and from our website. Further information about these tools is set out in our Cookies Policy.

Our Sites includes links to other websites or mobile applications whose privacy practices may differ from those of Zipcar. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy notice of any website you visit or mobile application that you use.

understanding your rights

You have certain rights in relation to your personal information. The availability of these rights and the ways in which you can use them are set out below in more detail.

Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact us at dpo@zipcar.com or in one of the ways provided in the Contact Information section at the end of this privacy notice.
Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information. This enables you to receive a copy of the personal information we hold about you and certain other information about it to check that we are lawfully processing it.

Correction: you are entitled to request that any incomplete or inaccurate personal information we hold about you is corrected.
Erasure: you are entitled to ask us to delete or remove personal information in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.

Restriction: you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Transfer: you may request the transfer of certain of your personal information to another party.
right to define post-mortem guidelines: If specifically provided for under your local law, you will have a right to define guidelines regarding the storage, erasure and disclosure of your personal data after your death.

Objection: where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on the legitimate interest or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.

Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.

If you want to exercise any of these rights, please contact us at dpo@zipcar.com or in one of the ways provided in the Contact Information section at the end of this privacy notice.

You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident, where we are based, or where an alleged infringement of Data Protection law has taken place. In the UK you can make a complaint to the Information Commissioner's Office (Tel: 0303 123 1113 or at www.ico.org.uk). In France, you can make a complaint to the Commission Nationale de l'Informatique et des Libertés (Tel: +33 1 53 73 22 22 or at www.cnil.fr). In Spain you can make a complaint to the Spanish Data Protection Office (Tel:+ 0034 901100099 or at www.agpd.es ). In Belgium you can make a complaint to the Commission for the Protection of Privacy (Tel:+32 (0)2 274 48 00 ) or at www.privacycommission.be ).

Zipcar is committed to providing you with reasonable and practical access to your information to allow you the opportunity to identify inaccuracies. If you are a member of Zipcar, you can review and correct personal information by clicking on the "my stuff" button and navigating through the "my account," "my reservations" and "my statement" pages. If you would like to access, delete and/or correct other personal information held by Zipcar, you can also contact us in one of the ways provided below and we will respond to your request within 30 days (or sooner if required by applicable law).

Please contact us if you wish to cancel your account or request that we no longer use your information to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain and use your information in order to make promotional offers to you (where we have the right to do so), unless you have opted out of receiving such communications.

Zipcar is committed to providing you with reasonable and practical access to your information to allow you the opportunity to identify inaccuracies. If you are a member of Zipcar, you can review and correct personal information by clicking on the "my stuff" button and navigating through the "my account," "my reservations" and "my statement" pages. If you would like to access, delete and/or correct other personal information held by Zipcar, you can also contact us in one of the ways provided below and we will respond to your request within 30 days (or sooner if required by applicable law).

Please contact us if you wish to cancel your account or request that we no longer use your information to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain and use your information in order to make promotional offers to you (where we have the right to do so), unless you have opted out of receiving such communications.

what security measures are used to protect my personal information?

The security of your personal information is important to us. We take reasonable steps to make sure your information is protected from unauthorised use, access, disclosure, alteration, destruction or loss. For financial or payment information, we use firewalls and Transport Layer Security (TLS) encryption. We take security extremely seriously but as no system is 100% secure, we can't completely guarantee the protection of your personal information, any more than any other organisation can.

We do not ask for financial or payment information, such as your credit card number, passcode, account number or pin number, in an e-mail, text or any other communication that we send to you. Please always check that any website on which you are asked for financial or payment information in relation to our reservations or services is operated by Zipcar groups. If you do receive a suspicious request, do not provide your information and report it by contacting one our member service representatives as set out in the Data Controllers and Contact Details by Country section.

You are responsible for keeping your account passcode, membership numbers and pin numbers safe and secure. Do not share those with anyone. If there is an unauthorised use or any other breach of security involving your information, you must notify us at the member services contact information below as soon as possible.

how might this privacy notice be changed?

We may change this privacy notice from time to time, so it is advisable to review it frequently. Changes to this privacy notice will be announced on our website or through similar means for a reasonable length of time prior to and following the change taking effect.

contact information

If you are making a reservation or visiting a local country version of our Sites in the following countries, the data controller is listed in the table below.

You can also contact our Data Protection Officer in respect of any issues or questions you have regarding our processing of your personal information. They act as the Data Protection Officer in respect of all of the data controllers listed below and can be contacted at:

It is important you take the time to read and understand the terms of this privacy notice. We may contact you by email, telephone, sms or other such means in connection with this privacy notice.

This privacy notice was last revised effective May 22 2018.

COOKIE NOTICE

This Notice describes how we use cookies and similar technologies on our website and mobile apps.

Cookie Notice was last updated on 22 May 2018.

We use cookies and similar technologies as described in this Notice. By consenting to this Cookie Notice, you agree that we can distinguish you from other users of our website and apps for the purposes set out below. This helps provide you with good user experience, tailored content and interest-based adverts. For example, we can recognise and remember important information that will make it more comfortable for you to browse our website or use our apps such as preferred settings.

What are Cookies and similar technologies?

A cookie is a small file of letters and numbers that we store via your browser on the hard drive of your computer or mobile device.

There are three main types of cookies:

Session cookies: specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you don't have to re-enter information when you navigate to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes;

Persistent cookies: record information about your preferences and are stored in your browser cache or mobile device; and

Third party cookies: placed by someone other than us which may gather data across multiple websites or sessions.

We use cookies for the following purposes:

Type of Cookie

Purpose of Cookie

Strictly necessary

These cookies are essential for you to browse our Website and use its features. The information collected relates to the operation of the Website (e.g. website scripting language and security tokens) and enables us to provide you with the service you have requested.

Functionality

These cookies remember the choices you have made, for example the country you visit our Website from, your language and any changes you have made to text size and other parts of the web pages that you can customise to improve your user experience and to make your visits more tailored and enjoyable. The information these cookies collect cannot be used to track your browsing activity on other websites.

Performance/analytics

These cookies collect information on how users use our Website, for example which pages you visit most often, whether you receive any error messages and how you arrived at our website. Information collected by these cookies is used only to improve your use of our Website. These cookies are sometimes placed by third party providers of web traffic and analysis services. We use Google Analytics. For information on how Google processes and collects your information and how you can opt out, please see the following link:https://tools.google.com/dlpage/gaoptout

Targeting or advertising

These cookies collect information about your browsing habits and inferred interests to make advertising more relevant to you. They are also used to limit the number of times you see an advert as well as to measure the effectiveness of an advertising campaign. These cookies are usually placed by third party advertising networks. They remember the other websites you visit and this information is shared with third party organisations, for example advertisers.

Social Media

These cookies allow users to share our website content on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies of the social media providers for how their cookies work.

You acknowledge that where we allow third parties to drop cookies, we have no control over those cookies or the data generated. Please refer to the third party's privacy policy for information on what information they collect and how they use it.

Google Analytics

Our websites use the web analytics service Google Analytics that is provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses "cookies". Cookies are small text files that are placed on your computer which allow analysing how you use the platform. The information generated by the cookie on your use of the platform will be transmitted to and stored by Google on servers in the United States. We have activated the so called "IP-anonymization" which means that your IP address will be truncated within the area of the European Union or the European Economic Area before being transferred to the United States. Only in exceptional cases the entire (ie. non-truncated) IP address will be transferred to a Google server in the US and truncated there. Google will use this information on our behalf for the purpose of evaluating your use of the platform, compiling reports on platform activity and providing other services relating to platform and internet usage. Google does not provide us with data that we may link back particularly to you. Your truncated IP address that is transferred to Google will not be associated with any other data held by Google. You may refuse accepting cookies by selecting the relevant settings of your browser. However, please note that if you do so you may not be able to use the full functionality of the platform. You can also opt out from being tracked via Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add-on under https://tools.google.com/dlpage/gaoptout.

Refusing or deleting cookies

Most internet browsers are set up by default to accept cookies. However, if you want to refuse or delete them (or similar technologies) please refer to the help and support area on your browser for instructions on how to block or delete cookies (for example: Internet Explorer, Google Chrome, Mozilla Firefox and Safari). Please note you may not be able to take advantage of all the features of our Website, including certain personalised features, if you delete or refuse cookies.

For more information on managing cookies, please visit www.youronlinechoices.eu which has further information about behavioral advertising and online privacy.

Changes to our Cookie Notice

This Cookie Notice may be updated from time to time.

If we change anything important about this Cookie Notice we will notify you through a notice on the website for a reasonable length of time prior to and following the change. You may also review the Cookie Notice by visiting our website.